Promoting Interoperability Fact Sheet Health Services Advisory Group (HSAG) provides this eight-page fact sheet to help providers with understanding Activities that are eligible for the Promoting Interoperability (PI) performance category bonus (formerly Advancing category), as part of the reporting required under the Merit-based Incentive Payment System (MIPS). The information contained here is Appendix B from the Centers for Medicare & Medicaid Services Promoting Interoperability Fact Sheet, located at https://www.cms.gov/medicare/quality- Payment-Program/Resource-Library/2018-Promoting-Interoperability-Fact-Sheet.pdf. Appendix B: Activities Eligible for the PI Perfromance Bonus This chart identifies the set of Activities from the Activities performance category that can be tied to the objectives, measures, and certified electronic health record technology (CEHRT) functions of the PI performance category and would thus qualify for the bonus in the PI performance category if they are reported using CEHRT. While these activities can be greatly enhanced through the use of CEHRT, we are not suggesting that these activities require the use of CEHRT for the purposes of reporting in the Activities performance category. Name Expanded Practice Provide 24/7 access to eligible clinicians or groups who have realtime access to patient s medical record Provide 24/7 access to MIPS eligible clinicians, groups, or care teams for advice about urgent and emergent care (for example, eligible clinician and care team access to medical record, cross-coverage with access to medical record, or protocoldriven nurse line with access to medical record) that could include one or more of the following: High Provide Expanded hours in evenings and weekends with access to the patient medical record (for example, coordinate with small practices to provide alternate hour office visits and urgent care); Use of alternatives to increase access to care team by MIPS eligible clinicians and groups, such as e-visits, phone visits, group visits, home visits and alternative locations (for example, senior centers and assisted living centers); and/or Provision of same-day or next day access to a consistent MIPS eligible clinician, group or care team when needed for urgent care or transition. Table continues on the following pages Page 1
Name Anticoagulant MIPS eligible clinicians and groups who prescribe oral Vitamin K antagonist therapy (warfarin) must attest that, in the first performance period, 60 percent or more of their ambulatory care patients receiving warfarin are being managed by one of more of these Activities: High Provide -Specific s are being managed according to validated electronic decision support and clinical tools that involve systematic and coordinated care, incorporating comprehensive patient education, systematic INR testing, tracking, follow-up, and patient communication of results and dosing decisions; For rural or remote patients, patients are managed using remote monitoring or telehealth options that involve systematic and coordinated care, incorporating comprehensive patient education, systematic INR testing, tracking, follow-up, and patient communication of results and dosing decisions; and/or Health Data or Data from Non- Setting Exchange For patients who demonstrate motivation, competency, and adherence, patients are managed using either a patient self-testing (PST) or patient-self- (PSM) program. The performance threshold will increase to 75 percent for the second performance period and onward. Clinicians would attest that, 60 percent for first year, or 75 percent for the second year, of their ambulatory care patients receiving warfarin participated in an anticoagulation program for at least 90 days during the performance period. Support (CEHRT Function Only) Page 2
Name Glycemic services For outpatient Medicare beneficiaries with diabetes and who are prescribed antidiabetic agents (for example, insulin, sulfonylureas), MIPS eligible clinicians and groups must attest to having: For the first performance period, at least 60 percent of medical records with documentation of an individualized glycemic treatment goal that: a) Takes into account patient-specific factors, including, at least 1) age, 2) comorbidities, and 3) risk for hypoglycemia, and High Health Data Support, CCDS, Family Health History (CEHRT functions only) b) Is reassessed at least annually. The performance threshold will increase to 75 percent for the second performance period and onward. Clinicians would attest that, 60 percent for first year, or 75 percent for the second year, of their medical records that document individualized glycemic treatment represent patients who are being treated for at least 90 days during the performance period. Chronic care and preventive care for empaneled patients Proactively manage chronic and preventive care for empaneled patients that could include one or more of the following: Provide -Specific Provide patients annually with an opportunity for development and/or adjustment of an individualized plan of care as appropriate to age and health status, including health risk appraisal; gender, age and condition-specific preventive care services; plan of care for chronic conditions; and advance care planning; Page 3
Name Use condition-specific pathways for care of chronic conditions (for example, hypertension, diabetes, depression, asthma and heart failure) with evidencebased protocols to guide treatment to target; Use pre-visit planning to optimize preventive care and team of patients with chronic conditions; Use panel support tools (registry functionality) to identify services due; Use reminders and outreach (for example, phone calls, emails, postcards, patient portals and community health workers where available) to alert and educate patients about services due; and/or routine medication reconciliation. Health Data or Data from Non- Setting Support, Family Health History (CEHRT functions only) of methodologies for in longitudinal care for high risk patients Provide longitudinal care to patients at high risk for adverse health outcome or harm that could include one or more of the following: Use a consistent method to assign and adjust global risk status for all empaneled patients to allow risk stratification into actionable risk cohorts. Monitor the risk-stratification method and refine as necessary to improve accuracy of risk status identification; Use a personalized plan of care for patients at high risk for adverse health outcome or harm, integrating patient goals, values and priorities; and/or Use on-site practice-based or shared care managers to proactively monitor and coordinate care for the highest risk cohort of patients. Provide -Specific Health Data or Data from Nonclinical Settings Page 4
Name Support, CCDS, Family Health History, List (CEHRT functions only) of episodic care practice Provide episodic care, including across transitions and referrals that could include one or more of the following: Routine and timely follow-up to hospitalizations, ED visits and stays in other institutional settings, including symptom and disease, and medication reconciliation and ; and/or Managing care intensively through new diagnoses, injuries and exacerbations of illness. of medication practice Manage medications to maximize efficiency, effectiveness and safety that could include one or more of the following: Reconcile and coordinate medications and provide medication across transitions of care settings and eligible clinicians or groups; Integrate a pharmacist into the care team; and/or conduct periodic, structured medication reviews. Support Computerized Physician Order Entry Electronic Prescribing (CEHRT functions only) or use of specialist reports back to referring clinician or group to close referral loop of regular practices that include providing specialist reports back to the referring MIPS eligible clinician or group to close the referral loop or where the referring MIPS eligible clinician or group initiates regular inquiries to specialist for specialist reports which could be documented or noted in the CEHRT. a Page 5
Name of documentation for practice/ process of practices/processes that document care coordination activities (for example, a documented care coordination encounter that tracks all clinical staff involved and communications from date patient is scheduled for outpatient procedure through day of procedure). a of practices/ processes for developing regular individual care plans of practices/processes to develop regularly updated individual care plans for at-risk patients that are shared what the beneficiary or caregiver(s). Provide (formerly ) Health Data or Data from Non- Setting Practice for bilateral exchange of patient information Ensure that there is bilateral exchange of necessary patient information to guide patient care that could include one or more of the following: Participate in a Health Exchange if available and/or Use structured referral notes Page 6
Name Beneficiary Engagement Use of certified EHR to capture patient reported outcomes In support of improving patient access, performing additional activities that enable capture of patient reported outcomes (for example, home blood pressure, blood glucose logs, food diaries, at-risk health factors such as tobacco or alcohol use, etc.) or patient activation measures through use of CEHRT, containing this date in a separate queue for clinician recognition and review. Provide -specific through Engagement Beneficiary Engagement Engagement of patients through implementation of in patient portal to an enhanced patient portal that provides up to date information related to relevant chronic disease health or blood pressure control, and includes interactive features allowing patients to enter health information and/or enables bidirectional communication about medication changes and adherence. Provide -specific Beneficiary Engagement Engagement of patients, family and caregivers in developing a plan of care Engage patients, family and caregivers in developing a plan of care and prioritizing their goals for action, documented in the CEHRT. Provide -specific ( Action) Safety and Practiec Assessment Use of decision support and standardized treatment protocols Use decision support and protocols to manage workflow in the team to meet patient needs. Support (CEHRT function only) Achieving Health Equity Leveraging a QCDR to standardize processes for screening Participation in a QCDR, demonstrating performance of activities for use of standardized processes for screening for social determinants of health such as food security, employment and housing. Use of supporting tools that can be incorporated in the CEHRT is also suggested. Health Data or Data from a Non- Setting Public Health and Data Registry Reporting Page 7
Integrated Behavioral and Mental Health Integrated Behavioral and Mental Health Name of integrated Primary Behavioral Health (PCBH) model Electronic Health Record Enhancements for Behavioral Health (BH) data capture Offer integrated behavioral health services to support patients with behavioral health needs, dementia, and poorly controlled chronic conditions that could include one or more of the following: Use evidence-based treatment protocols and treatment to goal where appropriate; Use evidence-based screening and case finding strategies to identify individuals at risk and in need of services; Ensure regular communication and coordinated workflows between eligible clinicians in primary care and behavioral health; Conduct regular case reviews for at-risk or unstable patients and those who are not responding to treatment; Use of a registry or certified health information technology functionality to support active care and outreach to patients in treatment; and/or Integrate behavioral health and medical care plans and facilitate integration through co-location of services when feasible. Enhancements to an electronic health record to capture additional data on behavioral health populations and use that data for additional decision-making purposes (for example, capture of additional BH data results in additional depression screening for at-risk patient not previously identified). High Provide -Specific Health Data or Data from a Non- Setting Health Data or Data from Non- Setting Questions? To learn more about submission requirements or the Quality Payment Program (QPP), please visit our QPP Service Center at www.hsag.com/qpp. Submit QPP and MIPS questions via email to HSAGQPPSupport@hsag.com or contact us at 844.472.4227 between the hours of 8:00 a.m. 8:00 p.m. ET. This material was prepared by Health Services Advisory Group, the Medicare Quality Organization for Arizona, California, Florida, Ohio, and the U.S. Virgin Islands, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. Publication No. QN--11SOW-D.1-08132018-01 Page 8